## Facts

- New York statutes granted Robert R. Livingston and Robert Fulton an exclusive, time-limited right to operate steamboats in New York waters, with unlicensed vessels subject to forfeiture.
- James Van Ingen and other respondents operated steamboats on the Hudson River without licenses from Livingston and Fulton.
- Livingston and Fulton sought equitable relief in New York Chancery to enjoin the unlicensed operations and enforce the statutory exclusivity.
- The Chancellor denied an injunction, reasoning that navigable waters are for common use and that exclusive navigation rights were inconsistent with general legal principles and constitutional protections.
- Livingston and Fulton appealed to the New York Court for the Correction of Errors.

## Issues

1. Whether New York’s statutes granting an exclusive right to navigate state waters by steamboat were constitutional under the U.S. Constitution.
2. Whether the monopoly could be upheld as a valid exercise of state power over intrastate navigation and commerce.
3. Whether a court of equity could issue an injunction to restrain violations despite statutory remedies providing forfeiture and an action at law (detinue).

## Decision

- The Court for the Correction of Errors reversed the Chancellor’s denial of injunctive relief.
- The court held the steam-navigation statutes constitutional and valid.
- The court held that Livingston and Fulton, as holders of the statutory exclusive right, were entitled to an injunction restraining unlicensed steamboat operations.
- The court held that the statutory forfeiture/detinue remedy did not bar equitable relief.

## Legal Principles

- A state may regulate and grant exclusive privileges affecting commerce and navigation that are purely internal to the state, absent conflict with federal law.
- State legislation encouraging technological improvements may confer limited exclusive rights without being invalid solely because it operates as a monopoly.
- State grants of exclusive operational privileges may coexist with the federal patent system where there is no direct conflict or preemptive federal enactment.
- When ongoing violations threaten continuing harm, equity may issue an injunction even if a statute also provides legal remedies; such remedies may be cumulative rather than exclusive.

## Conclusion

New York’s highest court upheld the state’s steamboat monopoly statutes as constitutional and enforceable, and it authorized injunctive relief to prevent continuing infringement even though the statutes also provided forfeiture and detinue as legal remedies.


Livingston v. Van Ingen, 9 Johns. 507 (N.Y. Ct. for the Corr. of Errors 1812)